INTRODUCTION

We are Cityviews, a group of companies offering online gambling services. Our services include Royal Vegas, Platinum Play, 7 Sultans, Vegas Palms, Euro Palace, Piggs Peak, Red Flush, All Slots, All Jackpots, Wild Jack, JackpotsinaFlash, Spin Palace, Ruby Fortune, Mummys Gold, Cabaret Club, Jackpot City, Riverbelle, Lucky Nugget, Spin Casino, Gaming Club, and Kiwis Treasures (collectively, the “Services”).

Cityviews is committed to safeguarding your privacy. This Privacy Notice outlines our data protection practices, including how we collect, use, disclose, and protect your Personal Information, and your rights regarding your Personal Information.

In this Privacy Notice, you will learn about:

• THE GROUP
• WHAT INFORMATION WE COLLECT
• MINORS
• HOW WE USE THE COLLECTED INFORMATION
• MARKETING
• WITH WHOM WE SHARE INFORMATION
• TRANSFER OF INFORMATION
• THIRD PARTY TRACKING TECHNOLOGIES
• THIRD PARTY SERVICES
• RETENTION OF PERSONAL INFORMATION
• YOUR RIGHTS
• HOW WE KEEP YOUR INFORMATION SECURED
• CHANGES TO THE PRIVACY NOTICE
• HOW TO CONTACT US

Read this Privacy Notice carefully. By using our Services, you agree to the Privacy Notice. If you have any questions or comments, contact our Data Protection Officer at: FORM

THE GROUP

Cityviews includes the following companies:

• For Canadian players: Baytree Interactive Limited (69691), a Guernsey registered company at Ground Floor, Kingsway House, Havilland Street, St Peter Port, Guernsey, licensed by the Kahnawake Gaming Commission, License number: 00892 (issued 16 February 2022).
• For players from elsewhere: Baytree (Alderney) Limited (No. 2012), an Alderney registered company at La Corvee House, La Corvee, Alderney, GY93TQ, licensed by the Alderney Gambling Control Commission (AGCC) on 15 December 2020, License Number 155 C1.

WHAT INFORMATION WE COLLECT

We collect two types of information from our Users:

Personal Information

• Registration details: When you open an account, you provide us with details such as username, password, first and last name, email address, gender, birth date, physical address, country, ID number, phone number, and occupation.
• Government-issued ID: For verification, we may ask for a copy of your ID and proof of address.
• Payment information: We collect payment details like your credit card number and bank account information.
• Voluntary information: Information you provide voluntarily while communicating with us.
• Device information: Identifiers such as UDID, IMEI, MAC address, browser fingerprinting, IP address, and geo-location data.
• Communications: We record or monitor communications, including emails, chats, and calls, for support, training, and security purposes.
• Social networks: If you register through a social network account, we access basic information from that account.
• Information from third parties: We collect information from third-party service providers, including credit history and other financial information relevant to our services.

Non-Personal Information

• The second type of information we collect is un-identified and non-identifiable information about users, gathered through their use of the Services (“Non-Personal Information”). This includes technical and aggregated usage information, such as the user’s operating system, browser type, screen resolution, browser and keyboard language, click-stream data, activities on the Services, visit duration, and related timestamps.
• For clarity, any Non-Personal Information linked to Personal Information will be treated as Personal Information as long as the connection exists.

Types of Non-Personal Information we collect:

• Technical information: To enhance the Services and improve user experience, we collect technical data from your device, including browser and operating system type, language preference, access times, and the domain name of the website you linked from.
• Gameplay information: We record gameplay data, such as deposits, bets, bonuses, session duration, and high scores. This information may be shared and published on our platforms.
• Device and connection information: If you download our software, we may collect information from your device for security and fraud prevention. This includes detecting software associated with fraudulent activity or checking if your connection uses a VPN or proxy.
• Analytics information: We collect data about your use of the Services, such as application usage, log files, user activity (pages viewed, time spent on pages, clicks, actions), timestamps, and alerts. This helps us troubleshoot errors and conduct research and analytics.
• Anonymous information: We may anonymize or de-identify collected information so it cannot personally identify you. We can use and disclose this aggregated or de-identified information without restrictions, including for advertising or marketing purposes.

MINORS

The Services are not intended for individuals under the age of 18 or the legal age of consent in their jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, do not use the Services or provide any Personal Information to us.

We reserve the right to verify any Personal Information collected. If we discover that a user who is not Legally of Age has shared information, we will discard it. If you believe a minor has shared information with us, please contact us.

HOW WE USE THE COLLECTED INFORMATION

We use your Personal Information for the following purposes:

• To set up, manage, and update your account.
• To provide and operate the Services (e.g., betting and payment processing).
• To communicate with you and inform you of updates and special offers.
• To market our Services and serve you advertisements, including behavioural advertising.
• To conduct analytics, statistics, and research to improve and customize the Services.
• For Customer Relationship Management, support, and troubleshooting.
• To develop, customize, and improve the Services based on user preferences.
• To provide a responsible gaming environment.
• To process your requests to exercise your User Rights.
• To identify and authenticate your access to certain features.
• To detect and prevent fraudulent and illegal activities.
• To investigate policy and User Agreement violations and enforce our policies.
• To resolve disputes related to your use of the Services.
• As required by law or regulation (e.g., KYC and Anti-Money Laundering requirements) or to comply with legal processes or government requests.

MARKETING

We, or our third-party subcontractors, may use your Personal Information (such as your name, address, email, and phone number) to provide you with promotional materials about our Services and related products, services, websites, and applications.

These may come from:

• Other companies within the Group
• White Label Brands
• Group’s business partners and affiliates (collectively, “Marketing Affiliates”)

We may share your Personal Information with our Marketing Affiliates to offer you different marketing promotions that we believe are relevant to you. These promotions may be delivered via email, post, SMS, or phone.

You can update your marketing preferences at any time through Customer Services. If you download our Software, notification software may also be installed on your device to send you updates about new features, service communications, offers, and promotions. By downloading the Software, you consent to receiving these notifications. To stop receiving notifications, you will need to manually uninstall the notification software from your device.

You can decline further marketing offers from us or our Marketing Affiliates at any time by contacting us via Live Chat. Note that even if you unsubscribe from marketing emails, we may still send you service-related updates and notifications.

WITH WHOM WE SHARE INFORMATION

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Notice. Personal Information will be disclosed to Recipients only as needed for specific purposes.

We share Personal Information with:

• White Label Brands and their service providers
• Companies within the Group and affiliated companies
• Subcontractors and third-party service providers (e.g., cloud computing companies, marketing affiliates, identity verification, and fraud prevention services)
• Credit reporting agencies
• Payment service providers, processors, and banks
• Third parties involved in the operation or promotion of In House Brands or White Label Brands
• Organizers of offline events or tournaments
• Hotels and flight companies (for offline events and promotions)
• Auditors, contractors, or advisers of the Group’s business processes
• Third parties investigating or preventing fraudulent or illegal activity (e.g., governmental authorities, police, banks)
• Licensing authorities, governmental and regulatory bodies
• Potential purchasers or investors in the Group or White Label Brands, or in the event of a corporate transaction (e.g., sale, merger, reorganization)

We share Personal Information for purposes such as:

• Storing information on our behalf (e.g., cloud computing services)
• Processing information to assist with business operations (e.g., payments, authentication, auditing, fraud prevention)
• Performing research, technical diagnostics, or analytics
• Communicating targeted advertising and promotional materials
• Protecting our rights or legal claims, enforcing policies, ensuring safety, investigating fraud, or addressing technical issues

TRANSFER OF INFORMATION

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection laws in these countries may not be as comprehensive as those in the EU.

We strive to protect your Personal Information in accordance with our Privacy Notice, using contractual means (such as approved contractual clauses for data transfer) or other safeguards.

If you feel your privacy has been violated or if someone has misused the Services, please contact us via Live Chat.

THIRD PARTY TRACKING TECHNOLOGIES

When you visit or access our Services, we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags, and other technologies (“Tracking Technologies”).

These Tracking Technologies allow us to automatically collect information about you and your device to enhance navigation, improve performance, and customize your experience. We also use this information for statistics, analytics, and to deliver tailored content and services.

Third parties may also collect information about you through Tracking Technologies. For more details, please visit our Cookie Policy.

THIRD PARTY SERVICES

While using the Services, you may encounter links to third-party websites, services, or applications. This Privacy Notice does not apply to these third-party sites, even if they are accessible through our Services.

These third-party sites are independent from the Group, and we are not responsible for their privacy practices or legal matters. We encourage you to read their privacy policies and terms of use before interacting with them.

You assume all risks of using third-party websites, services, or applications. We are not liable for any issues arising from your use of them.

RETENTION OF PERSONAL INFORMATION

If you have an account with us, we will retain your Personal Information while your account is active. We may also retain your data to comply with legal obligations, such as gambling regulations, Know-Your-Customer, and Anti-Money Laundering requirements.

We may keep your Personal Information longer if necessary for legitimate interests, such as fraud prevention and record keeping.

If you wish to delete your Personal Information, please email us at [email protected], and we will make reasonable efforts to address your request.

YOUR RIGHTS

You may contact us at any time to:

1. Access or delete your Personal Information.
2. Change or update your Personal Information (e.g., correct errors).
3. Restrict or stop further use of your Personal Information.
4. Receive your Personal Information in a machine-readable format.

These rights are subject to legal requirements, including gambling regulations and other reporting obligations. We may also correct, update, or remove incomplete or inaccurate information as needed.

HOW WE KEEP YOUR INFORMATION SECURED

We take great care to secure your information. We have implemented physical and technological safeguards to prevent unauthorized access, maintain data security, and use information correctly. These safeguards vary based on the sensitivity of the information.

We use industry-standard procedures and controls, such as:

• Secure network topology with intrusion prevention and firewall systems.
• Encrypted communication.
• Authentication and access control.
• External and internal audits.

While we take reasonable steps to protect your information, we cannot guarantee against unauthorized access or misuse. We make no warranty that we can prevent such access.

CHANGES TO THE PRIVACY NOTICE

We reserve the right to change this Privacy Notice at any time, so please check this page frequently. We will notify you of substantial changes via the Services or by email. These changes will take effect seven (7) days after the notice is provided. Other changes are effective as of the “Last Revised” date, and your continued use of the Services after this date means you accept and agree to the changes.

HOW TO CONTACT US

If you have any questions about the Services or the information we collect and how we use it, please contact us via the chat facility. We will try to respond within a reasonable timeframe. If you are unsatisfied with our response, you can contact the applicable data protection supervisory authority:

Office of the Data Protection Authority (ODPA)

Block A, Lefebvre Court, Lefebvre Street, St. Peter Port, Guernsey, GY1 2JP
Email: [email protected]
Phone: +44 1481 742074

CITYVIEWS COOKIE POLICY

Introduction

When you visit or access our Services (such as websites or applications operated by us, or when you interact or engage with our content), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other tracking technologies ("Tracking Technologies").

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.

We also allow third parties to collect information about you through Tracking Technologies.

What are cookies?

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

Storing Tracking Technologies

We store Tracking Technologies when you visit or access our Services (for example when you are visiting our websites) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies".

Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

What types of Tracking Technologies do we use?

There are four main types of Tracking Technologies:

• Strictly necessary Tracking Technologies
  These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Services, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons - for example to detect violation of our policies and for support or security features.
• Functionality Tracking Technologies
  These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
• Performance Tracking Technologies
  These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
• Marketing or Advertising Tracking Technologies
  These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app. Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

Tracking Technologies	Type	Purpose
Analytics Cookies	First party Tracking Technology	Performance Tracking Technologies These Tracking Technologies are used to collect information regarding how you interact with the content on our Services, attribution purposes (for example, the referral URL), etc. We use the information to compile reports, calculate the revenues due to us and, help us improve the Services and to offer personalized products and content.
Other cookies	First and Third party Tracking Technology	Strictly necessary Tracking Technologies These unlisted cookies might be in use on internal sections of the Services, in order to customize and simplify the user experience on the site by remembering choices you made and your log in credentials.

How to manage your cookie settings

Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including "Do Not Track" requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively. Should you wish to update your preferences at any time, click here.

• Turning off cookies via your web browser
  Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
• Information about cookies is usually found in the "Help" section of the web browser. Below are some links to some commonly used web browsers:
  • Chrome
  • Chrome for mobile
  • Internet Explorer and Microsoft Edge
  • Mozilla Firefox
  • Safari
• Turning off third party cookies
  You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.